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Policies

Updated May 29, 2018

Scope

  1. This Privacy Policy describes the practices of Convergence Blended Finance (“Convergence”, “we”, “our” or “us”) regarding the collection, use, and disclosure of Personal Information (as defined below) of online visitors or members of our web sites, online resources, and mobile applications. This Policy describes (i) the types of Personal Information collected (ii) the manner of collection, (iii) the purposes of the collection, (iv) its disclosure and/or transfer, (v) the measures we take to protect the security of Personal Information and (vi) your rights regarding Personal Information. This Policy does not apply to information which does not qualify as Personal Information.

  2. This Policy does not apply to the collection, use, and disclosure of Personal Information by third-parties, where Convergence does not have any control over the collection of Personal Information or their privacy practices.

  3. Except for legal and regulatory requirements applicable to Convergence and for the Purposes outlined in Section 8, Convergence, its employees and service providers do not have access to any Personal Information.

  4. By “Personal Information” we mean, except to the extent provided by applicable law, any information about an individual that allows such individual to be identified. Personal Information may include but is not limited to the first name, last name, address, telephone number, date of birth, and email address.

  5. Convergence is committed to privacy and the protection of Personal Information and to complying with applicable Canadian Personal Information and privacy laws and regulations.

Collection of Personal Information

  1. Convergence may collect the following types of Personal Information:

    • name, postal address, email address, telephone number, date of birth
    • information relating to professional skills, credentials and experiences

  2. Personal Information may be collected in the following manner:

    • when contacting us or communicating with us via the telephone, by mail, email or facsimile regarding one of our products, services, websites or online initiatives
    • online while visiting one of our websites or online initiatives
    • online via one of our online websites or online initiatives in data forms and/or fields queries
    • when using one of our electronic or mobile devices, application or tools
    • when submitting your resume to us for employment purposes

Purposes

  1. Personal Information may be collected and used for the following purposes (the “Purposes”):

    • to respond to your inquiries on our products or services
    • occasionally, as permitted by applicable laws and regulations or if you have given us your consent, to communicate with you (via phone, mail, email or online) about our products and services
    • to fulfil registration in one of our websites or online resources
    • to enable us to create your profile, customize and personalize the content, tools and resources available to you as a member of one of our websites, online resources or mobile devices, applications or tools
    • to permit us to improve our products, services, websites, online resources, mobile devices, applications or tools
    • to allow us to enhance the quality of our services
    • to allow us to assess your employment application

  2. Information may be consolidated and aggregated in an anonymous manner in order to generate statistics in relation to our products, services, websites, online resources, mobile devices, applications or tools or for reporting purposes to government authorities.

  3. Any other collection and use of your Personal Information will be solely with your consent, for the purposes disclosed to you at the time of collection, or as permitted or required by law and regulations. Only the amount of Personal Information necessary to fulfill the intended Purposes is collected and/or retained.

Information we Share

  1. We do not disclose Personal Information except as described herein, unless otherwise authorized and required by applicable law or relevant Court proceedings. We may disclose Personal Information to regulatory and governmental authorities for the Purposes outlined above. Where Personal Information is disclosed, only the amount of Personal Information necessary to fulfill the intended Purposes is disclosed.

  2. Personal Information about you will be accessible only to authorized employees of Convergence and/or of its affiliates who need to have access to the Personal Information in order to perform their duties in relation to the Purposes.

  3. Convergence may retain agents, consultants and/or suppliers (collectively “third-party service providers”) to assist and support our business and services. These third-party service providers may have access to Personal Information within the scope of the Purposes if it is required for the performance of their services. When we transfer or provide access to Personal Information to third party service providers, we contractually require that such providers put in place adequate security measures to protect Personal Information against unauthorized access and disclosure, including requiring that they respect this Privacy Policy and be responsible for the security of the Personal Information disclosed.

  4. Your Personal Information may be consolidated, aggregated and rendered anonymous for internal research or reporting to governmental authorities purposes and disclosed to third parties as such (i.e. in an unidentifiable manner).

  5. The collection, use, and disclosure of information contemplated in this Policy may involve a transfer of the information to jurisdictions located outside your country of residence that may not have equivalent laws and rules regarding Personal Information. The reasonable contractual other measures we may take to protect Personal Information while processed or handled by these third parties are subject to applicable foreign legal requirements, for example lawful requirements to disclose Personal Information to government authorities in those countries.

  6. We reserve the right to transfer any Personal Information we have about you in connection with the sale or transfer of all or a portion of our business or assets or rights relating thereto. In such case, we will do our best efforts to obtain guarantees that your Personal Information will continue to be protected as per the applicable Canadian personal information and privacy laws and regulations.

Records Retention

  1. Convergence will only retain Personal Information as long as needed to fulfill the relevant Purposes. The Personal Information will be held primarily in an electronic database located on our premises or those of our service providers. The file containing your Personal Information will be made available to the authorized employees, third-party service providers of Convergence and/or its affiliates who need to access the information in connection with the Purposes.

Security

  1. We maintain appropriate administrative, technical and physical safeguards and use appropriate commercially reasonable efforts to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and all other unlawful forms of processing of the Personal Information in our possession.

Personal Information Data Breach

  1. In the event of a Personal Information data breach that Convergence has determined to pose a “real risk of significant harm” to any individual or institution, Convergence has in place a procedure that involves (a) notifying the Office of the Privacy Commissioner of Canada about the breach, (b) notifying those individuals and institutions affected by the breach, (c) notifying any organizations that Convergence has determined could help mitigate any harm resulting from the breach and (d) conducting an investigation as to the cause of the breach and insuring further risk to any Personal Information has been mitigated.

Your Rights

  1. You have certain rights to access and rectify your Personal Information; in order to exercise this right, or if you have any questions, comments or concerns about this Privacy Policy, to contact us about withdrawing consent to our use or disclosure of Personal Information or to obtain information on our practices relating to the use of foreign service providers, you may contact us at [email protected]. If the Personal Information collected is incorrect, inaccurate or outdated, we will correct such information within a reasonable period of time.

  2. You have the right to request the deletion of any of your Personal Information stored by Convergence. Such requests can be made to Convergence by contacting us at [email protected]. Convergence will comply with your request within a reasonable period of time once we have reasonably verified your identity. During the processing of such a request, Convergence will ensure that your Personal Information will be removed from any Convergence database that contains the information, such as our customer relationship database and website databases. However, due to securities laws, Convergence must continue to maintain some information.

  3. Convergence respects and observes the provisions set forth in the applicable Canadian federal or provincial legislation regulating the protection of Personal Information in the private sector. To the extent there is additional protection afforded to an individual pursuant to such applicable privacy legislation, and same is not set forth herein, Convergence agrees to take such measures to give full effect to such additional protection. Convergence reserves the right to modify this Privacy Policy at any time.

  4. You have the right to opt-out of any marketing-related communications sent by Convergence at any time. A link to "unsubscribe: from future marketing-related communications will be provided in each of our marketing-related email communications. Additionally, opt-out requests may be emailed to [email protected]. All such requests will be processed within a reasonable period of time.

Cookie Policy

  1. Cookies are tiny files stored on your computer, created when you visit a website, that provides a website the ability to help improve your browsing experience. This section will explain how and why Convergence, and any third-party services we use, use cookies as part of our website and how these cookies will affect your experience on our website(s). For a more detailed explanation on cookies, we recommend you read the following Wikipedia article on HTTP Cookies.

  2. Convergence uses cookies to help improve a user’s browsing experience in the following ways:

    1. Convergence creates a cookie when you visit our website and are prompted with our cookie-policy message. We use this cookie to track your choice (accept or decline) so that for subsequent re-visits to our website, you are no longer prompted for the same choice. Without this cookie, you will always be prompted with our cookie-policy prompt.

    2. Convergence creates a cookie when you log into our website with a valid username or password. This cookie is used to track the fact that you are logged in and ensures that as you navigate and browse through our website – you continue to remain logged in throughout your browsing session. Without this cookie, you will not be able to use the website as a logged in user.

  3. It is possible to disable cookies on your bowser via your browser’s settings, which will prevent our website or any third-party service we use from creating or using cookies. However, disabling cookies will significantly impact the use and experience of our website(s) and you will not be able to use any of our member-only services. We recommend that you DO NOT disable cookies.

  4. Convergence also uses third-party services that will create cookies on behalf of Convergence:

    1. Convergence uses website analytics services that helps track, anonymously, your browsing activity on our website. Such tracking involves, but is not limited to, information such as: the duration of time you spent visiting a page, the number of times you have visited a page, how many pages you have visited during your browsing session, as well as information such as your browser and geographical location. Convergence uses this information to help improve your browsing experience by determining which of our pages are performing well and which are not via the collected metrics. We then use this information to implement new features and content.

    2. Convergence uses a third-party service for our newsletter service. This third-party service uses a cookie to track if you have already signed-up for a newsletter to ensure that you are not re-registering if you have already done so previously.

    3. Convergence uses a third-party service to provide a live-chat support service on our website. This chat support service allows you to contact a member of the Convergence staff and have a live conversation with them if they are online and available. If no Convergence staff member is available, you are then allowed to leave a message which will automatically be sent as a notification for a Convergence staff member to contact you at a later time. A cookie is used to help track your usage of this service and allow you to return back to our website and continue with any previous conversation(s) you may have had.

    4. The following are the third-party services Convergence uses that create cookies on your browser:

Sexual Exploitation and Abuse Prevention Policy

Purpose

Convergence recognizes its obligation and responsibility to operate in a manner consistent with the fundamental principles of human rights and are committed to the prevention of and response to sexual exploitation and abuse. Convergence recognizes that sexual exploitation and abuse of vulnerable people is a global phenomenon. It is vital that sexual exploitation and abuse are not perpetrated or compounded by those whom Convergence employs, contracts, or otherwise directs. It is crucial that we all understand the problem of sexual exploitation and abuse and our own role and responsibility in preventing it.

The U.N. Secretary-General defines sexual exploitation and abuse as follows:

  • Sexual exploitation refers to any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially, or politically from the sexual exploitation of another.
  • Sexual abuse refers to an actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.
  • Sexual activity with children (persons under the age of 18) is prohibited regardless of the age of majority or age of consent locally. Not knowing or mistaking the age of a child is not a defense.

Policy

Convergence will not tolerate sexually abusive or exploitative acts being perpetrated by employees, volunteers, consultants, contractors, grantees, representatives or anyone associated with the delivery of its program. Employees are bound to uphold this policy and to report people or incidents that they believe contravene it. Convergence senior level staff and corporate leadership have a duty to ensure that allegations of sexual exploitation and abuse are investigated and that appropriate disciplinary measures are taken. Convergence also has a duty to provide appropriate assistance to any victims of sexual exploitation and abuse by its staff.

Responsibilities

It is the responsibility of Convergence employees and anyone who works with us to report incidences of sexual exploitation and abuse being perpetrated by anyone within Convergence. Senior level staff, in particular, are responsible for creating and maintaining an environment in which employees, volunteers, consultants, contractors, grantees, and representatives know what Convergence expects from them and feel able to report any suspicious or inappropriate behaviour.

Making a Report

Anyone has the right to make a complaint about the behaviour of those associated with Convergence.

Parties external to Convergence may send a written complaint by email to the CEO or the Board Chairperson. It is recommended that complaints be made as quickly as possible after the incident takes place, recognizing that this may not always be possible or likely with allegations of such a sensitive nature. An investigation can go ahead no matter how long ago an incident occurred and no matter whether the alleged victim wishes to take an active part. How to report guidelines are referenced below.

Investigations

Convergence will investigate allegations of sexual exploitation and abuse in a timely and professional manner and will engage professional investigators or secure investigative expertise as appropriate.

Investigations are an internal process and therefore do not involve the police or other external authorities. Investigations are carried out so that Convergence can have the best information possible on which to base its decisions concerning conduct and potential consequences.

We may alert the appropriate authorities if, following an investigation, we judge that:

  • A crime has taken place;
  • Confidentiality can be ensured;
  • The victim is in agreement; and
  • Those associated with the case will not be subject to further abuse, disrespect or violence.

Convergence is not required to disclose its response or the actions resulting from any information that may be provided or reported. Safety of participants will prevail.

Victim Assistance

Victims will receive immediate support as necessary, in line with the needs of the victim, as appropriate.

Consequences

Employees who contravene Convergence’s clearly stated expectations of their sexual conduct will be subject to disciplinary action that may result in dismissal. Volunteers and representatives will have their relationship with Convergence terminated. Contractors, consultants, and grantees who contravene Convergence’s expectations will have their contract ended.

As outlined above, the police or other external authorities may be involved under certain circumstances.

How to Report Guidelines:

To make a report, provide your name and contact information so we can assess and follow-up with your concerns. If you do not provide your name and contact information, you may file your report anonymously, however it may limit the ability to investigate.

To the extent possible, please include the following information:

  • All facts describing the alleged event or matter;
  • The name and title of each person involved;
  • Dates, times, frequency, and locations; and
  • Documentation, witnesses, or other evidence available.

Where to report: HR team – [email protected] CEO – [email protected] Board Chair – [email protected]

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